The Memphis appeal. [volume] (Memphis, Tenn.) 1886-1890, 1887-12-11
THAT CAUSEY STREET LOT
PRESIDENT HADDEN's ANSWER TO
THE STATES cHANcERY BILL.
A Full Explanation Of How the Prop
erty Was neutrality-suspicious. for
Improvements and Interest Of the City
Therein-Important Document.

CAN'T 4 Patterson, filed his answer yes
terday afternoon to the States chancery
BILL looking toward settlement OF the
cily's interest in the Causey street stables.
Following is the answer in full:
"The State Of Tennessee, for the use OF the Taxing
District Of Shelby county, VS.. David T. lladden
"The answer of David =. Hadden TO the bin Of
complaint heretofore filed herein.
''This defendant for answer TO said bill
says:
ale admits that the Taxing District OF
Shelby county is municipal corporation,
created by the laws OF the State OF Tonnes
see, and that various officers are desig-
mated by the law of its creation to perform
the duties therein specified. lie admits
that among the officers are the board of
fire and police commissioners, composed
OF three members, one OF whom is the
president of said board and executive oili-
Ger Of said Taxing District, and that he is
now such president and executive officer,
and has been for several years past. lie
admits that board OF public works is also
created by the said act OF Incorporation,
and that its duties are prescribed therein
substantially as is in the bill OF complaint
set FORTH
Gle further admits that the members OF
said board OF fire and police commission
ers, and of public works, are prohibited by
law from being interested in any contract
made with, or in behalf of; the said Taxing
District
'Ileiurthermore admits that ON or about
the 18th of September 1885, he became
the owner, 10y purchase, of the lot of
ground mentioned in the bill Of complaint,
which is therein with substantial accuracy
slflgpriha1 Nc N
boundary thereof, correct description Of
which will be hereinafter accurately given.
Defendant denies that at the time
named in the said bill of complaint, to-
wit, in the fall Of 1885, or the early part Of
1886, or at any other time, he has Illegally
expended the sum of $4,000, or any other
sum belonging 10 the Taxing District. lie
has made no expenditures in the erection
OF stables and buildings upon said proper
~, except in manner and form and under
circumstances hereinafter detailed and set
forth.
defendant states that the real facts of
The transaction referred 10 in the bill Of
complaint are a. follows: The Taxing Dis
trict OF Shelby county had never, during
defendants administration, been the
owner OF stables and storage room neces-
sary for the accommodation OF the teams,
wagons, carts tools and material used in
the engineers and board OF health depart
ments.
at had, prior to 1885, been compelled
20 rent buildings for that purpose at Il large
annual outlay.
'ln the spring Of 1856 il was occupying
building ON the north side oi Court
street, for which 1t was payinga monthly
rent OF $40, which was wholly insufficient
In size for the needs of the departments,
and, besides, WIS badly located and in a
dilapidatcd condition. IL became an abso-
lutte necessity TO procure additional room
for the engineers department, which me-
cessity could only be met by either rent
ing another additional building, which
would have cost at least ~ much, II not
more, than the one then occupied Tor the
Taxing District 10 erect stables with proper
shed room ior the storage Of material,
carts tools. etc. II was, on many accounts,
every way preferable that the Taxing Dis
trict should own it, own stables. Especial
" was this ~ because the same could be
erected at comparatively small cost, which
would be fully repaid in the saving Of
rents IN the course OF three or four years.
"Ths being the situation of Affairs. de-
PENDANT, ~ was his duty, began an inyesti-
CATION NJ "a the most suitable place Tor the
erection OF said stables.
"rhe Taxing District at that time owned
n lot fronting on the west side OF Second
street. Immediately north Of an alley be-
tween Adams and Washington streets.
''Deiendnnt at finst favored building
upon this lot, but upon consultation with
the officers al the engineers department il
was determined that, by reason OF the fact
that Il was in the heart Of the city, aud that
IL would be Objectionable 10 have q stable
at that point, especially rs the garbage aud
other carts used in hauling the refuse irom
the city would be stored there, and are OK
trcmely offensive, that this would not be u
suitable place.
defendant examined, in conjunction
with the Taxing District engineer, lot
on the corner OF Orleans and Washington
streets, also owned 10y the Taxing District,
but found that this lot was unsuilably To-
Gated, too small, and, beside, was adjacent
60 large number Of private residences,
and for these reasons did not answer the
purpose.
"'rhe Taxing District was also the owner
81 lot Of ground situated ON the south
west corner Of Elliott and Causey streets.
Said lot has front OF 500 feet on Causoy,
running back with Elliott about 200 feet,
"
shape ~ wedge. The Taxing District has
been the owner Of this lot for more than
thirty years, without any adverse claims
thereon from any quarter, and ~ defend
ant then supposed and still sup
poses, md Is advised aud believes has
an undspuicd right and title thereto.
This property was unimproycd and bring
ing the district no income whatever. IL
was suggested 10 defendant by the Taxing
District engineer, or his assistant, that this
LOT was admirably located Cor the purpose
of erecting suitable stable upon II, aud
that Il was located near the southern
boundary line Of the district in n spancly
ihhabiied portion thereof
"Dcicndant being himself satisfied ~ 10
the advantageous situation Of tho said lot,
ordered the engineer 20 examine the same,
prepare suitable plans Tor said stable
"Tiis WIS accordingly done, and the en-
gincers reported, IN substance, that, after
preparing his plans lac found the l0t was
TOO small, ly reason Of lis irregular shape,
20 erect such stable aud s,Omgc.rnom ~
was desirable and necessary for the Hc.
commodailun 81 his department. The lots
oi ground 10 purchased by the defendant
IN 1885, Law Immediately adjoining the said
lot ~ owned lev the Taxing District. his
northern line ran along the entire south
line Of sail lot, aud q bayou, known rs
- bayou, ran along the entire south
limo Of his said lot and was included there
y iu, pmcicall, separating the lot 50 owned
by him from that owned by the Taxing
District. Tie engineer suggested TO the
defendant that II he were permitted 10 pile
and cover over the said bayou and add the
same 10 The said lot owned 10y the Taxing
District, il would give ample room for the